Interpretation ID: aiam2950
Nissan Motor Co.
Ltd.
P.O. Box 1606
560 Sylvan Avenue
Englewood Cliffs
New Jersey 07632;
Dear Mr. Murakami: This is in response to your letter of September 29, 1978, and i confirmation of your conversation with Mr. Schwartz of my office. Since the agency was considering petitions for reconsideration when your letter was received, we concluded that it would be more helpful to respond to your letter after the revised standard was issued. A copy of the amendments to the standard and a copy of the notice of proposed rulemaking to further amend the standard are enclosed.; Your letter raised a number of question concerning Federal Moto Vehicle Safety Standard No. 115. These questions will be answered in the order posed in your letter.; Q-1. The term 'line' is defined in S34 of the standard to mean 'a nam which a manufacturer applies to a family of vehicles within a make which have a degree of commonality in construction, such as body, chassis or cab type'. You are correct in saying that 'B210' is a Datsun 'line.'; Q-2. You ask whether it is necessary in designating a vehicle 'line' t distinguish between independent and rigid axle systems within the same model of vehicle. The answer to your question is no. It is not necessary to make this distinction. In your example, either Case 1 or Case 2 would be correct.; Q-3. You ask whether it is necessary in designating a vehicle 'line' t distinguish between different lengths of wheel base within the same family of vehicles. Again, the answer to your question is no. In your example, either Case 1 or Case 2 would be correct.; Q-4. You ask whether it is necessary in designating vehicle 'body type to distinguish between a 2-door vehicle and a 4-door vehicle. It is necessary to make this distinction.; Q-5. You also ask whether it is necessary in designating vehicle 'bod type' to distinguish between a sedan and a hardtop. It is not necessary to make this distinction.; Q-6 You ask whether it would be necessary in designating a vehicl 'series' to distinguish between a Datsun 810 with air conditioning and power steering and a Datsun 810 with these features. It is not necessary to make this distinction.; Q-7. You ask whether it would be necessary in designating a vehicl 'series' to distinguish between a Datsun B210 with a cigarette lighter and a Datsun B210 with out a cigarette lighter and with a less elegant interior. It is not necessary to make this distinction. A Datsun B210 with two doors would have a different 'body type' than a datsun B210 with four doors, however.; Q-8. You ask whether in designating vehicle 'engine type', you may us the same character (e.g., 'H') to designate different engines so long as they are within *different* 'lines', or whether you must use different characters for each engine type you manufacture.; The vehicle description section (VDS) of the VIN is used to describe group of vehicles with common characteristics. One of these characteristics is engine type. The VDS is a 'code word' which is translated as a whole into the appropriate specification. Each VDS is unique, and the use of a specific character in one VDS does not bar its use in another VDS, whether or not the meaning is the same or different. Consequently, 'HB210' can represent a Datsun B210 with an 85 CID displacement engine and 'HA100' can represent a DATSUM(sic) 510 with a 119 CID displacement engine. In your example, both Column 1 and column 2 would be permissible.; Q-9. you ask whether it is necessary to uniquely distinguish all engin types within a *make*, or whether it is sufficient to distinguish engine types within a line. As explained above, each vehicle descriptor section is unique. Consequently, you may use the same characters in more than one VDS provided the VDS can be translated into the specific engine type. In your example, either Column 1 or Column 2 would be permissible.; Sincerely, Joseph J. Levin, Jr., Chief Counsel